1.       Introduction

Norges Bank, as central bank, is given considerable authority and trust. The Bank makes decisions that are of considerable importance for the business sector and private households. The Bank manages confidential information that could have an impact on market conditions. Large sums of money are involved in the Bank’s purchases of goods and services. The Bank shall perform their work with integrity and according to high professional standards and comply with sound business practices. Norges Bank and its employees are required to act in an ethically responsible manner, comply with applicable laws and regulations and persistently maintain high ethical awareness. The Executive Board has stated that Norges Bank does not accept any form of misconduct or financial crime such as corruption, money laundering or terrorist financing. 

Corruption erodes ethical and moral values and is a threat to the rule of law, fundamental human rights and democracy. It also creates discrimination, is an impediment to social justice and undermines fair competition. Corruption is often linked to organised crime, money laundering and the financing of terror. Combating corruption is therefore about more than just protecting the Bank’s interests. It is also an important part of creating a sustainable economy and furthering political and social development.

The risk of corruption is mainly that of a person soliciting, receiving or accepting the offer of an undue advantage on the strength of his or her position either as an employee of the Bank or as an external consultant, supplier or subcontractor.

Key elements of the anti-corruption programme include management backing, risk management, ethics, procurement, security requirements financial reporting and systematic training and controls.

2.   Risk management and corporate governance

The Ministry of Finance has issued a specific regulation on risk management and internal control at Norges Bank. Norges Bank takes a holistic and systematic approach to managing all risks. Risk assessments are performed regularly as an integral part of operational management. Corruption risks are treated the same as other risks in terms of risk levels, risk tolerance, preventive measures and the handling of any incidents. 

Systematic risk assessments are performed periodically. These include an evaluation of the quality of controls and the status of risk reduction measures, and a review of incidents and other risk indicators. The results are reported to the Executive Board twice a year.

Norges Bank has rules on authorised signatories governing who is entitled to sign on behalf of the Bank. Two signatures are normally required. Authorities are documented and are also set out in job descriptions. The Governor has set limits for the value of framework agreements, purchasing contracts and so on that managers may sign.

3.     Ethics

The Executive Board has issued ethical principles for employees of Norges Bank, and the Governor has issued Conduct Policy for employees in Norges Bank Central Banking. These set out strict rules on confidentiality, inside information, conflicts of interest and accepting invitations. There are restrictions on employees’ right to trade in financial instruments, foreign exchange and fixed-income products. There is an ongoing obligation to disclose personal trading, secondary occupations and gifts. Employees must not accept gifts and personal benefits for themselves or others in relation with their work. The rules on gifts are intended partly to prevent corruption. The Bank has procedures on handling suspicion of money laundering and terrorist financing. 

All employees have an independent responsibility to safeguard Norges Bank’s reputation. Employees must refrain from acts that even lawful, that they should understand may damage the Bank’s reputation. Anti-corruption is about more than prescriptions and prohibitions set out in laws and regulations – it is also about individual attitudes and choices. 

4.    Procurement

Procurement must comply with the rules on public procurement and the relevant provisions of the Freedom of Information Act. The procurement process must observe basic principles of competition, equal treatment, predictability, verifiability and proportionality. A central procurement function is involved in all purchases. 

Suppliers with access to the Bank’s premises or systems must undertake to adhere to a special set of ethical guidelines based on ethical principles laid down by the Executive Board. Suppliers and third parties acting on their behalf must agree, for example, to refrain from illegal acts, including any form of corruption. 

5.     Security

Norges Bank sets security requirements for both employees and suppliers. 

Background checks for employees and temporary staff are an important part of the anti-corruption programme. All those who work at Norges Bank, whether as employees or on a temporary basis, must sign a confidentiality undertaking. The same applies to participants in invitations to tender.

As a general rule, employees, temporary staff and supplier personnel with unaccompanied access to Norges Bank’s premises or Norges Bank’s internal information and information systems must have a security clearance based on a background check. The decision on security clearance is based on an overall individual assessment of the information obtained. Information from police certificates and credit checks is normally included. Employees and supplier personnel are to be given information and training to ensure that the individual has the knowledge, motivation and attitudes required for the desired conduct in terms of security. 

The Bank sets security requirements for suppliers on the basis of risk assessments. These security requirements are included in the contracts with suppliers. Besides background checks for supplier personnel, there might be requirements for information systems, technical requirements, requirements for the storage of information and requirements for the physical security of premises. Norges Bank also conducts security inspections of suppliers.

6.   Financial reporting

Financial reporting helps identify suspected financial irregularities and corruption. Well-functioning and documented division of responsibilities is fundamental when it comes to financial assets. The Bank’s financial statements are prepared in accordance with a specific regulation on its annual financial statements, as well as the requirements of the Accounting Act and International Financial Reporting Standards (IFRS). Norges Bank’s accounting policies are documented in an accounting manual. Processes (including controls) leading up to financial disclosures are updated regularly and reviewed annually. The financial statements are audited by an external auditor under an agreement with Norges Bank’s Supervisory Council.

7.      Information, training and development

Employees in Central Banking are to have a clear understanding of the work on ethics and anti-corruption. Everyone is given information and training on the ethical rules. Special training and information is provided for all new recruits in the form of confirmation that the rules have been read and understood, individual training and e-learning. Every year, all employees must complete a questionnaire on the ethical rules and confirm that the rules have been read and understood. The GRC unit also provides information on the intranet and bespoke training for specific units and individuals. GRC deals with any questions about the rules and assists line management with training for suppliers.

Norges Bank Central Banking has its own intranet page on anti-corruption which brings together both external and internal rules. The page includes links to relevant websites.

8.    Control and follow-up

Norges Bank Central Banking has an internal control model based on three lines of defence.

The first-line functions are operational risk management and control activities performed by the business lines. They identify, assess, decide on and manage risks and are responsible for risk mitigating measures and for compliance with internal and external requirements. All managers are responsible for risk management in their areas of responsibility and under their authority and shall have the authority to implement risk mitigating measures.

The second-line functions have an advisory and monitoring role. They are responsible for developing and maintaining risk management and internal control frameworks; monitor, verify and report on risk and the effectiveness of controls and measures; facilitate implementation of internal control; and follow up compliance with external and internal rules. The Director of risk control and compliance has the right and duty wherever it is deemed necessary to independently report material risks to the Executive Board. This Director is responsible for the anti-corruption programme for Norges Bank Central Banking. 

The third-line function (internal audit) has an independent audit role. It shall support the Executive Board in its follow-up of Norges Bank’s activities by providing independent assessments and advice on the Bank’s risk management and internal control.